Submitted to the Army Corps of Engineers by Laura Jackson, Vice President, on behalf of the Juniata Valley Audubon Society.

Map of the Lake Raystown area from the Huntingdon County Natural Heritage Inventory

To Whom it May Concern:

Please accept this letter as a formal comment submitted by the Juniata Valley Audubon Society, a chapter of the National Audubon Society, with over 300 members residing in Blair, Bedford, Huntingdon, Mifflin, and Centre Counties in central Pennsylvania. We appreciate the opportunity to provide comments to be considered in the development of the Raystown Lake Master Plan Revision.

Juniata Valley Audubon Society (JVAS) recognizes the diverse recreational resources offered by the Raystown Lake, its economic development potential, the importance of the flood control, and its clean hydropower. More importantly, however, we value the significant amount of relatively undisturbed habitat: approximately 18,000 acres (84%) of the Raystown Lake Project is forested. Since Terrace Mountain provides a forested backdrop to much of the eastern lake shore, we know that sustainable forest management is key to maintaining not only the viewscape, but the quality of water in Raystown Lake. We commend the US Army Corps of Engineers on their work to maintain this important habitat, so vital to maintaining clean water and healthy fish and wildlife.

Furthermore, we applaud the Corps' efforts to establish a Bat Conservation Area on Terrace Mountain in the Hawn's Bridge Peninsula area to maintain roosting and foraging habitat for northern long-eared bats and Indiana bats, as well as other forest dwelling bat species. JVAS supports managing these areas to mimic old growth conditions, which will create better habitat for roosting bats.

Another type of habitat quite different from the forested expanses are the rare shale barrens that occur in the Raystown Lake Project Area. We understand that the shale barren communities in Bedford and Huntingdon counties are one of the most unusual, and also most endangered, ecosystems in Pennsylvania. They are few in number and small in acreage, but contain endemic plant species found only in this habitat. The eleven shale barrens in the Raystown Lake Project are each significantly important since they vary in geographical and environmental features, as well as types of flora and fauna. We appreciate the Corps' dedication to protecting them by designating them as "Natural Areas," which will be preserved in their natural state.

We ask that the Corps continue to protect the shale barrens as designated Natural Areas by placing total restriction of any development in the area, and protecting the steep slopes and fragile environment of the barrens areas from disturbance, except for scientific investigation. Especially important is the restriction of foot travel on the slope and prohibition of watercraft docking at the base of the cliffs.

We are concerned, however, that the 9-acre shale barrens on the Hawn's Bridge Peninsula is under threat from future development. In the 1994 Master Plan, the Corps pledged complete protection and did not agree to any development on the Hawn's Bridge Peninsula. We know that the current Master Plan update is considering changing the use of this area. In keeping with the Corp's pledge to protect one of Pennsylvania's rarest and most endangered habitats, we would like to emphasize that this complete protection will only occur if the entire Hawn's Bridge Peninsula is protected from development. The 1994 master plan emphasized protection of the eastern shore, which includes the Hawn's Bridge Peninsula. We feel the eastern shore and Terrace Mountain should remain protected.

The Shale Barrens are also designated as part of the Raystown Biological Diversity Area (BDA), a Natural Heritage Area documented by the Western Pennsylvania Conservancy in the Huntingdon County Natural Heritage Inventory. Within the strata of BDAs, Huntingdon County recognizes Hawn's Bridge Peninsula to be the highest ranking: an "Exceptional Biological Diversity Area." See map at end of letter.

Our request to protect Hawn's Bridge Peninsula from development is supported by many local residents, including the Coalition to Protect Hawn's Peninsula. It is important to note that our request to protect Hawn's Bridge Peninsula is also aligned with the Huntingdon County Comprehensive Plan, 2007 Supplement. Sadly, the businesses and organizations that are promoting development of Hawn's Bridge Peninsula are at odds with the Comprehensive Plan.

Although it is not regulatory, the Comprehensive Plan is an important guiding document for Huntingdon County as it contains, "A Vision for the 21st Century." The Elements of the Vision include, "protection of farmland, forest land, natural resources, and the environment," while emphasizing new development "in and around existing boroughs and villages." It further emphasizes developing "greenways along rivers and ridges."

This vision is further detailed in this excerpt, " The vast majority of land in the County will remain in productive private rural land uses such as agriculture, forestry, and recreation. A system of “Greenways” will be established along mountain ridges, streams, and rivers to protect water quality, to provide habitat for wildlife, to enhance recreational opportunities, and to protect scenic beauty. "

One policy supported in this Vision does include, "the development of a year-round, full-service resort at Raystown Lake." However, we ask that such development should not be along mountain ridges such as Terrace Mountain, or impact rare habitats like shale barrens. Such a resort at Raystown Lake should be on Army Corps property where development already occurs, not in an exceptional Biological Diversity Area like Hawn's Bridge Peninsula.

In conclusion, Juniata Valley Audubon Society supports the protection of the eastern shore of Raystown Lake, specifically the endangered shale barrens which include the one located on Hawn's Bridge Peninsula. We request that Hawn's Bridge Peninsula be reclassified as an Environmentally Sensitive Area and that Terrace Mountain remain as a Low Density Recreation Area in the new Master Plan.

The ecological evidence provided in the Huntingdon County Natural Heritage Inventory demands that the Hawn’s Bridge peninsula be designated as an Environmentally Sensitive Area in the Master Plan Revision.

The Hawn's Bridge peninsula is part of the Raystown Dam Natural Heritage Area (Biological Diversity Area) identified in the Huntingdon County Natural Heritage Inventory. The Inventory characterizes such areas as "containing plants or animals of special concern at state or federal levels, exemplary natural communities, or exceptional native diversity." The Huntingdon County Natural Heritage Inventory was administered by the Huntingdon County Planning Commission and identifies and maps Huntingdon County’s most significant natural places. The study investigated plant and animal species and natural communities that are unique or uncommon in the county. It also explored areas important for general wildlife habitat and scientific study. The inventory is a tool for informed and responsible decision-making.

The area in which a marina and other facilities are proposed includes red cedar-mixed hardwood rich shale woodland, and Virginia pine - mixed hardwood shale woodland communities. These rare habitats support two plant species endemic to shale barrens: the shale barrens evening primrose (Oenothera argillocola) (PA Threatened) and Kate's mountain clover (Trifolium virginicum) (PA Endangered). Several invertebrate species associated with shale barrens and the surrounding xeric forest also are found there. These include the southern pine looper moth (Caripeta aretaria), the promiscuous angle (Semiothisa promisuata), and a noctuid moth (Properigea sp.)

According to the Huntingdon County Natural Heritage Inventory, "The shale barren communities and associated plant species depend upon the harsh conditions found on these steep, dry slopes where competition from other species is low. Disturbances that can lead to the introduction of exotic and aggressive species are one of the largest threats." The establishment of a marina and associated amenities on the Hawn's Bridge Peninsula would certainly cause the types of disturbances which the Inventory warns against.

In addition, the Hawn's Bridge Peninsula is clearly visible from the Hawn's Overlook and from the Allegrippis Trails. From an aesthetic viewpoint, converting the forested peninsula to an entertainment-oriented facility with a marina would create an eyesore.

Furthermore, Terrace Mountain, adjacent to the Hawn’s Bridge peninsula, should be designated as Low Density Recreation because it contains a Bat Conservation Area, the Terrace Mountain Trail, and steep topography that is unsuitable for development. Visitors to Raystown Lake value the wild nature of the eastern side of the lake. Development should be confined to the western side of the lake, which already has infrastructure to support it.

Therefore, for ecological and aesthetic reasons, I strongly support the designation of the Hawn's Bridge peninsula as an Environmentally Sensitive Area and the designation of Terrace Mountain as a Low Density Recreation area.

Juniata Valley Audubon Society is pleased to promote the Bird Habitat Recognition Program. A yard sign like the one above and a Habitat Discount card are included with your $25 donation to PA Audubon. Be sure to list Juniata Valley Audubon Society as the Audubon Chapter in your area.

No property size limits

Sign (see above) is included with registration! (9" x 12", Metal)

Homes, schools, businesses, parks, and public land can join

Help us promote Healthy Yards that are easy on birds, babies and bank accounts

Habitat Discount Card will help you save money at businesses across the state

Your Bird Habitat could qualify for a special award! Juniata Valley Audubon Society will award a certificate and $25 to one outstanding Bird Habitat in each of the following counties: Bedford, Blair, Centre, Cambria, and Huntingdon. To apply, contact JVAS VP Laura Jackson at jacksonlaura73@gmail.com or call 814-652-9268. Remember, enter the Bird Habitat Program first.

Improving the quality of land for wildlife is the single most constructive step we can take to assist wild bird populations.Stephen Kress, Audubon Biologist

The weather forecast for Tuesday night is calling for snow and bitter cold, so the JVAS Board has decided to cancel the Jan. 16 Members’ Night meeting. While regrettable, this is precisely why we don't schedule a speaker in January — so that we can cancel if we have to. The forecast sounds especially dire for Bedford County late tomorrow afternoon.

The JVAS Blair County Christmas Bird Count (CBC), centered on Culp, will be held on Saturday, December 16, 2017 with a Tally Dinner (aka “tally rally”) to be held at The Dream Restaurant, starting at 5 P.M. The pay-your-own dinner is open to all, so you can attend even if you can’t help with the CBC. The Dream is located at 1500 Allegheny St., Hollidaysburg, PA.

We hope YOU will be a counter this year! We are always in need of more participants, so check with birder friends and invite them to participate, too. Participation is free. In addition to field surveys, we need feeder watchers. If you live in the count circle (within 7.5 miles of Culp), you are encouraged to record the birds you see on your property or at your feeder.

Counters will be assigned a section of the circle to cover, so if you have a favorite area, be sure to sign up early. Register by calling Laura Jackson. You will receive a map showing which part of the circle to cover, a species checklist, and pointers on any bird hot spots that might be in your part of the circle. We will assign the count areas in early December, so if you have a favorite area that you want to cover, contact Laura before December 10.

Also, we hope you will attend the Sunday, Dec. 3 Pre-CBC Workshop to help us organize the event. We will meet at 2:00 pm in Penn State Altoona's Hawthorn Building. Call Laura if you plan to attend.

Juniata Valley Audubon Society is proud to help sponsor local screenings of two fascinating and important nature documentaries this fall. Hometown Habitat: Stories of Bringing Nature Home, narrated by renowned entomologist, author and native plants expert Doug Tallamy, will be shown at the Canoe Creek State Park Education Center on Saturday, September 30 at 1:00 PM and at St. Luke's Episcopal Church in Altoona on Monday, October 16 at 7:00 PM. Chasing Coral, a Netflix documentary about the planet's disappearing coral reefs that the New York Times called "an emotional race against time," will be shown at the Altoona Area Public Library on Thursday, October 12 at 6:00 PM.

These screenings are in addition to our regular monthly program meetings, and are co-sponsored with other local groups (because screening movies isn't cheap), but we've included them in our programs calendar for easy reference.

Hometown Habitat

Award winning director, Catherine Zimmerman, and film crew traveled across the country to visit Hometown Habitat heroes, who are reversing detrimental impacts on the land and in the water of major U.S. watersheds, one garden at a time. They wound their way through the watersheds of Florida, the prairies of the Mississippi River Basin, the streams and rivers of the Rocky Mountains, the Chesapeake Bay, the Great Lakes and Columbia River to share success stories and works-in-progress that celebrate conservation landscaping that re-awakens and redefines our relationship with Nature.

Along with the everyday habitat heroes, Catherine and crew introduce us to ecologists, entomologists and other experts who share the science behind how today’s ‘native-plants-know- best’ enthusiasts, landscape architects and conservation groups are helping 20th century-minded city planners, businesses and developers appreciate the myriad 21st century benefits of low-maintenance, seasonally-dynamic and eco-healthy landscapes.

The stories they traveled to tell touch on all aspects of the benefits of native plants and brings to light a sense of community that makes conservation landscaping possible. These are the stories.

That's from the description on the film's website. It's worth pointing out that JVAS includes many such "habitat heroes" in its own membership, such as past president Stan Kotala, whose yards near Altoona are a showcase for native wildflowers, and current president Laura Jackson and her husband Mike, whose mountainside acreage near Everett serves as a sort of outdoor laboratory for conservation and habitat restoration. Laura sent along some recent photos of their yards to help make the case that switching to native plants doesn't represent any sacrifice in garden quality:

Laura says that this shows two flower beds full of spring blooms: blue woodland phlox, white foamflower, golden Alexander, wild geranium, wild ginger, Canada violets, and dwarf crested iris. There's also a patch of dandelions in the far right of the photo. The Jacksons let the dandelions go to seed in hopes of attracting white-crowned sparrows, which migrate through our area in the spring but nest farther north. The trees are white-flowering dogwood, wild black cherry, American redbud, and wild apple. All plants are native except the apple tree and the dandelions.

A summer-blooming native flower bed of mostly purple coneflower, black-eyed Susans, cardinal flower, and Heliopsis (ox-eye, or false sunflower). There is a small bog garden in the middle that contains native pitcher plants, sedges, purple violets, and ladies tresses orchids. In the foreground you can see creeping phlox that bloomed in the spring and a small pool with a water lily in it. All are natives, although the water lily is a cultivar of our native white waterlily. The trees in the background are white-flowering dogwood, white spruce, sweet gum, and black locust. Laura notes that the white spruce is not considered to be native to southern PA, but they had very few evergreens on their property, and it attracts bugs which are eaten by golden-crowned kinglets. The kinglets stay here all winter and only eat insects, even in the coldest of weather, so the white spruce helps to provide food for them.

If all this whets your appetite to learn more, be sure not to miss one of the screenings on September 30th or October 16th, which should spark lively discussions afterwards. The first screening, at Canoe Creek, will be followed by an optional walk to look at non-native and native plants and to discuss their impact on native wildlife.

Chasing Coral

Coral reefs around the world are vanishing at an unprecedented rate. A team of divers, photographers and scientists set out on a thrilling ocean adventure to discover why and to reveal the underwater mystery to the world.

Chasing Coral was directed by Jeff Orlowski and produced by Larissa Rhodes. The film took more than three years to shoot, and is the result of 500+ hours underwater, submissions of footage from volunteers from 30 countries, as well as support from more than 500 people from various locations around the world.

Visit their website to learn more about how you can involved. An essential first step, of course, is to watch the film with us at the Altoona Libary on October 12th. There will be free refreshments and a short discussion after the film for those who can stick around.

Peregrine falcons nest on rocky cliffs, under bridges, and on city buildings in Pennsylvania. This wild falcon was photographed by Mike Jackson as it returned to its nestlings under a bridge near Lock Haven.

Juniata Valley Audubon Society's evening program series resumes at the Bellwood-Antis Library in Bellwood on Tuesday, September 19 with a free dinner provided at 6:30 pm, and the program beginning at 7:00 pm. Mark Shields and Randy Flement will present "Trapping and Banding Migrant Raptors on Tussey Mountain.” (View the listing on our website, as well as all of our other upcoming programs and field trips for the fall.)

Mark and Randy's talk will cover the history of their banding efforts on Tussey Mountain, the size of the raptor flight, and the species of raptors that they see and capture, including photos of the birds in flight and in-hand. They'll also describe their trapping methods and banding procedures. A special part of the program will be an opportunity to see a live falcon — Mark’s Peregrine Falcon, Thistle.

Mark Shields is a retired USAF officer. He worked as a raptor biologist prior to joining the USAF. He has been a falconer for over 40 years, as well as being a raptor propagator. Since 1983, he has been a raptor bander and has worked under four Master Bird Banders. Mark continues to stay busy as an artist making reproduction medieval artifacts.

Randy Flament has been a wildlife photographer since 1980. As he says, "I just love being in the woods leaning as much as I can about anything in the wild." Photography allows him to share some of that with other folks, but he prefers to document seldom-seen behavior rather than just take generic portraits of animals. He has been working in the timber business for 40 years.

It was an easy decision for the Board of Juniata Valley Audubon Society to present our 2017 Conservation Award to the Stephen Gerhart family who live a few miles south of Huntingdon, Pennsylvania. Although the Gerharts are not Audubon members, they embody the environmental ethics that characterize many Audubon members: love of the land; conservation of bird and other wildlife habitats; and the fortitude to stand up to big corporations that destroy forests without the landowner’s permission.

Elise and Ellen Gerhart represent the Gerhart family, which received the 2017 Conservation Award from Juniata Valley Audubon Society on April 22, 2017. This Award, received on Earth Day is bittersweet, since Sunoco has cut trees on their land for a new gas pipeline that places their home within the 1,000-foot blast radius. (photo: Mike Jackson)

The Gerharts placed their 27-acre forested property in the Forest Stewardship Program about ten years ago, a Pennsylvania Department of Conservation and Natural Resources Bureau of Forestry program that helps landowners develop goals so their forest is sustainable and healthy for people and wildlife. It is a program intended to create a legacy for the Gerharts — or it did until two years ago, when the Gerharts got a knock on their door from a land agent, informing them that Sunoco Logistics planned to construct the Mariner East II pipeline under their property, including under their pond and through the forested wetlands. The Gerharts refused to take the money offered by Sunoco and to this day steadfastly refuse to accept any payment.

When I visited the Gerharts on Earth Day, Ellen showed us how Sunoco - without the Gerharts’ permission - cut trees in the riparian area of the stream and on the steep slopes adjacent to the wetlands. Sunoco claimed the trees were cut because the space was needed for a work area, but it is hard to imagine how workers would be able to use equipment on such a steep slope without extensive earth movement. The DEP file clearly states that, “support sites such as pipe/contractor yards, are to be sited on previously disturbed areas.”

Ellen straddles the small stream that flows above the pond, in an area that used to be forested. Although the stream was designated as a “Waterbody Crossing,” workers cut all the trees right to the edge of the stream, as well as the forested wetlands. (photo: Laura Jackson)

The Gerhart family is just one of hundreds of families in Pennsylvania faced with property destruction and safety concerns caused by Sunoco’s plans to construct about 306 miles of pipeline across Pennsylvania. On February 13, 2017, the Pennsylvania Department of Environmental Protection (DEP) approved the Chapter 105 and 102 pipeline permits for the project officially known as the PA Pipeline Project/Mariner East II. Almost 30,000 comments were sent to the DEP during the public participation process prior to that decision. Many of those comments were from landowners who were concerned about their family’s safety, since many miles of the pipeline will be located very close to schools and homes.

According to the DEP file, the Pipeline Project will transport up to 700,000 barrels per day of natural gas liquids (propane, butane and ethane) from the Utica and Marcellus Shale formations in Ohio and western Pennsylvania for both domestic and international markets using two new pipelines that are mostly found in the existing right of way corridor for the current Mariner East pipeline system. The Project will supply propane at various exit routes across Pennsylvania and terminate in Marcus Hook, Pennsylvania where fuels will be exported for international markets. The fact that domestic markets are included allowed Sunoco to obtain eminent domain, so affected families felt hopeless, and accepted the money offered by Sunoco.

What sets the Gerharts apart from many of the affected landowners is their continued resistance — they are still saying “NO.” Using similar tactics seen in western states to protect the redwoods and sequoias, Elise sat in a tree for two weeks in 2016, while nearby trees were cut all around her. Her mother, Ellen, who was not afraid to confront the workers face to face, was arrested and jailed for three days. Elise was criminally charged later. Fortunately, the disorderly conduct and contempt of court charges were eventually dropped against Ellen, Elise, and activist Alex Lotorto.

Elise Gerhart was arrested last year because Sunoco could not cut a tree she was sitting in. Both of these trees were saved because of “tree sitters.” (photo: Mike Jackson)

Sunoco claims the project disturbance will total 273 acres in Huntingdon County, causing extensive forest fragmentation. Although the three acres of disturbance at the Gerhart property doesn’t seem like much, it is symbolic of a greater concern: that of social injustice impacting rural families where the value of land and forests is worth far more than a few development dollars. Sunoco touts the potential for jobs and economic development opportunities, but rural landowners know that the environmental footprint of energy development grows bigger each year: pipelines, electric transmission lines, wind turbine projects, fracking wells, industrial solar projects — all of these energy-related development projects will continue to expand while open space contracts. Cities like Philadelphia plan to benefit from the pipeline project, but it is at the expense of rural forests and families.

Juniata Valley Audubon Society applauds the Gerhart family for trying to protect their property from industrial development.

RAYSTOWN LAKE, Pennsylvania - After a rigorous review process in accordance with federal policy and regulations, the U.S. Army Corps of Engineers (Corps), Baltimore District, has determined they cannot further consider authorization of Lancer Resources, L.P. (Lancer) recreational development's proposal in the Hawn's Bridge area of the Raystown Lake Project because it is not consistent with the current Raystown Lake Master Plan (MP).

The current MP for Raystown Lake dates back to 1994 and placed an emphasis on protecting the southeast shore, which includes the Hawn's Bridge area. Existing Corps policy reflects that the effective lifespan of a MP is 15- 25 years. Additionally, legislation contained in the recent Water Infrastructure Improvement of the Nation Act (WIIN), Section 1309, signed into law December 2016, requires the MP for the Raystown Lake be updated.

Col. Ed Chamberlayne, commander, Baltimore District, stated that re-entering the MP process would allow the Corps to address any proposed development. "We will immediately seek funding, personnel, and other resources to begin the master plan update," said Chamberlayne. "The update will include public input at appropriate times and preparation of corresponding National Environmental Policy Act (NEPA) documentation."

Once funds are made available, the process to complete updates to the MP could take between 18-24 months.

JVAS will be sure to assist in providing input as the plan revision process proceeds.

Note: Ian Gardner was inspired to organize the CACAO 2017 Expedition after participating in our Birding for Conservation trip to Honduras in February, 2016. This initiative is the first research project under the auspices of the newest JVAS Committee: Partners in Neotropical Bird Conservation. Contact Laura Jackson if you would like to get involved in conservation and education projects focusing on migratory birds.

Cacao is the Honduran colloquial name for the threatened Red-throated Caracara, a species of raptor that has nearly disappeared from Central America in the past few decades. It is also the acronym for a small but passionate cooperative of multi-national conservationists. We planned to spend three weeks this past January in Honduras on a research expedition to two locations in the remote eastern portion of the country, Reserva Biologica Rus Rus in Gracias a Dios and Parque Nacional Botaderos in Olancho. Our goals were to work with local conservation pioneers and preserves to survey and promote the wide diversity of bird life in these special yet threatened regions. We were able to meet our funding goal for the trip thanks to the support of many individuals and several Audubon Society chapters like JVAS.

We knew beforehand that these federal lands, Reserva Biologica Rus Rus and Parque Nacional Botaderos, were protected by title alone. During our expedition we learned why. Both areas are remote, at least a very rough 4 hour drive from the closest ICF facility (Instituto de Conservacion Forestal). But they also host an incredible diversity of flora and fauna, particularly birds.

The male Vermilion Flycatcher is brightly colored and often perches in conspicuous places as it scans for insect prey. Habitat destruction is the greatest threat to this colorful species.

We recorded over 280 bird species in the dimorphic landscape of Rus Rus. This area is comprised of two distinct ecosystems: expansive pine savanna and dense gallery* forest. Each contains a unique suite of species that is constantly evolving, so researchers are recording more species with each visit. Our expedition recorded range expansions for over 20 species and found such notables as Harpy Eagle, Crane Hawk, Jabiru, Black Rail, Green Ibis, Steely-vented Hummingbird, Scaled Pigeon, Northern Potoo, Yellow Tyrannulet, Aplomado Falcon, and Snowy Cotinga.

In Olancho, we surveyed miles of mountain trails in the central highlands and recorded over 200 species. Our top target was the pine forest denizen Red-throated Caracara, which we missed, but we were told of many recent encounters. We did see several other target birds such as Ocellated Quail, Buff-breasted Flycatcher, Olive-sided Flycatcher, Golden-winged Warbler, Golden-cheeked Warbler, and Red Crossbill. We also surveyed the lowland portion of Isidro Zuniga’s Las Orquideas Nature Preserve, where we documented a Wedge-tailed Sabrewing, a hummingbird with an isolated population that can only be found in this small region of Honduras.

Protected forests in eastern Honduras also face serious threats from natural resource extraction companies and cattle ranchers. Mining and Hydropower projects destroy hundreds of hectares and divert miles of rivers in Olancho. Cattle ranchers are recent migrants to the Rus Rus region and are illegally grabbing land to clearcut for cattle pastures. However, a determined community of environmentalists is standing up. These activists are literally risking life and limb to protect the forests, as you read in last year’s article about the late Berta Caceres. Fortunately we never faced any threats during this expedition and were able to talk with local communities and learn about these pressing conservation issues from their perspectives.
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* Gallery forests are forests that form as corridors along rivers or wetlands and project into landscapes that have fewer trees, such as grasslands or deserts.